QA-M-026 Quality Assurance Manual Environmental, Health and Safety (EH&S) Management

Table of Contents

1. Management Statement
2. General
3. EH&S Policy
4. Management EH&S Committee
5. General EH&S Program
6. References
7. Attachments

1. Management Statement

Environmental, Health and Safety (EH&S) Program

The protection and well-being of our human assets has Company Management’s highest priority, support and participation. This support is also applied to the preservation and conservation of the environment and of the material assets in the form of plant installations and property. Therefore, Company Management promotes EH&S as a key consideration in plant design, procurement and construction as well as in Company’s own organization. Equally important is the accomplishment of engineering, procurement and construction in accordance with applicable laws, regulations, codes, standards and client’s requirements.

All employees are responsible for working safely, working environmentally conscious and for producing a safe product and are responsible for the continuous development of an EH&S culture throughout the organization.

In order to ensure EH&S consciousness in all aspects of work, Company maintains a General EH&S Program with the purpose to locate, prevent and correct such conditions that could result in possible accidents, injuries and/or damage to environmental and material assets. This is achieved by monitoring EH&S in Company’s home and field offices and throughout all phases of project execution.

The General EH&S Program defines the overall policy and direction for controlling all environmental, health and safety aspects and identifies areas of responsibility.

The General Manager is ultimately responsible for the EH&S performance of Company, while the Manager of Safety is charged with the responsibility of maintaining the documented system and for monitoring its effectiveness, implementation and continuous improvement.

For each project the final responsibility of EH&S resides with the Project Manager.

We must continually demonstrate to our external and internal clients our commitment to excellence in achieving EH&S goals. Therefore, it is incumbent upon staff members, at all levels, to strictly maintain and adhere to the established EH&S standards.

Original signed by: .................................

Name:
Vice President & General Manager Europe

Date:

2. General

This section describes the General Environmental, Health and Safety (EH&S ) Program in Company's office(s) and project operations.

3 EH&S Policy

Priority is given by Company to the safety and health of human resources, as well as the preservation and conservation of the environment and of the material assets.

To meet these objectives:

• Company maintains a high standard of EH&S for all those using its buildings and sites.
• Company ensures that the installations designed and/or constructed by Company and materials and equipment procured for and supplied to its clients, are safe, environmentally friendly and without risk so far as is reasonably practicable.

These objectives are stipulated in a " Management Statement - General EH&S Program" (see section 26.1).

4. Management EH&S Committee

To achieve a total EH&S performance commitment throughout the company, a Management EH&S Committee (EH&S C) is established (see attachment 2).

The EH&S C is composed of the following permanent representatives:

• General Manager (Chairman)
• Director Human Resources
• Director Construction
• Manager Offices Services (Chief Enterprise Assistance Services)
• Manager Environmental
• Manager Safety (Coordinator)

The EH&S C interfaces with all other Department and Group Managers to seek advice, advance awareness and promote EH&S activities.

5 General EH&S Program

In order to make the EH&S policy effective, Company's instituted, General EH&S Program (see attachment 1) covers the two main objectives:

• Office EH&S Program
• Projects EH&S Program

The General EH&S Program provides the elements of a formalized and structured approach to control and assure that all aspects relating to EH&S are adequately implemented by Company (ref.26.6.1), and encompasses e.g.:

• the establishment of a Management EH&S Committee;
• an appointed Company Manager of Safety;
• the integrated documented General EH&S Program;
• the promotion of safety and environmental consciousness;
• EH&S training.

The Manager of Safety reports to the General Manager and has prime responsibility for maintaining the documented General EH&S Program and for the monitoring of the implementation thereof.

In principle, Company's General EH&S Program follows the rules as laid down in the:

• ISO 9001, "Quality Systems - Model for Quality Assurance in design/development, production, installa­tion and servicing";
• VCA** Safety Assurance System” - checklist for evaluation of safety, health and environmental assurance systems of contractors in the (petro) chemical or related industries”.

EH&S Control is the process of ascertaining that the required EH&S standards have been incorporated in the work. It is exer­cised by the supervisory personnel of the functional departments and the project task forces.

EH&S Assurance is a management function that includes auditing of the EH&S performance of the functional departments and project task forces. Individuals that perform safety assurance are independent of the departments or project task forces responsible for the work.

Specific items of the General EH&S Program are described in the following sections.

5.1 Office EH&S Program

The Office EH&S Program covers:

a. ARBO Beleidsplan;
b. Enterprise Assistance Service Program.

The Office EH&S organization is shown in attachment 2.

The Director Human Resources is responsible for the composition, implementation and maintenance of the ARBO Beleidsplan, including the coordination of the “Arbeidsomstandigheden Wet” (ARBO Law) requirements.

The Chief Enterprise Assistance Service is responsible for the maintenance, updating and implementation of the Enterprise Assistance Service Program, including the maintenance of contacts with local authorities with respect to the Enterprise Assistance Service.

The Projects EH&S Program covers:

Engineering EH&S Program (ref.26.6.5);

Field Construction EH&S Program (ref.26.6.6).

The Manager Environmental is responsible for the composition, implementation and maintenance of the Engineering EH&S Program.

The Director Construction is responsible for the composition, implementation and maintenance of the Field Construction EH&S Program.

On a project a typical EH&S organization is established as shown per attachment 3. The actual composition of the project EH&S organiza­tion shall be determined and specified by the Project Manager at the start of the project.

Detailed project related responsibilities of key personnel shall be defined in the Project Procedure and Execution Manual. Major EH&S responsibilities are as follows.

The Project Manager has the ultimate responsibility for EH&S for the project.

The Project EH&S Engineer (if assigned to a project) is responsible for monitoring and coordi­nating the implementation of the Project Home Office EH&S Plan.

The Project Construction Manager has the prime responsibility for EH&S at site and initiates the preparation of the site EH&S plan.

The Site Safety Engineer’s responsibility is to establish and monitor the coordination of the implementation of the Site EH&S Plan.

A Project Procedure and Execution (PPE) Manual written for a project (ref.26.6.2), shall include or refer to the specific project HO and site EH&S requirements.

The specific project EH&S requirements may be described in a Project HO EH&S Plan (ref.26.6.7) and/or in the Project Site EH&S Plan (ref.26.6.8). Both documents may also form attachments to the PPE Manual.

6. References

26.6.1

7 Attachments

1. General EH&S Program

2. General EH&S Program Organization Chart

3. Project Task Force EH&S Organization (typical)

1. General EH&S Program

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2. General EH&S Program Organization Chart

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3. Project Task Force EH&S Organization (typical)

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